IUCN Otter Spec. Group Bull. 41(1) 2024

REPORT
THE CURRENT STATUS OF REGULATION OF ASIAN SMALLCLAWED OTTERS Aonyx cinereus TRADE IN JAPAN
Yumiko OKAMOTO1,2,*, Chris R. SHEPHERD2,3 and Hiroshi SASAKI2,4
1

WWF Japan, 3F. Mita Kokusai Bldg., 1-4-28 Mita, Minato-ku, Tokyo, 108-0073, Japan
2
IUCN SSC Otter Specialist Group
3
Monitor Conservation Research Society, Big Lake Ranch, B.C., Canada
4
Chikushi Jogakuen University, 2-12-1 Ishizaka, Dazaifu, Fukuoka 818-0192, Japan* Corresponding author: Yumiko Okamoto - yumiko.okamoto@wwf.or.jp(Received 6th July 2023, accepted 14th August 2023)
Abstract: The Asian Small-clawed Otter Aonyx cinereus is traded internationally to supply
demand for pets, both legally and illegally. In 2019, the species was elevated from being
listed in Appendix II of the Convention on International trade in Endangered Species ofWild Fauna and Flora (CITES) to Appendix I, which generally prohibits international trade,as trade was deemed a threat to the conservation of this species. Although the Japanesenational legislation strictly protects the CITES Appendix I-listed species, it is still possible
to trade the Asian Small-clawed Otters domestically, subject to the necessary registration
procedures. Here we look at current trade levels of Asian Small-clawed Otters in Japan andthe impact of the CITES up-listing.
Citation: Okamoto, Y., Shepherd, C.R., and Sasaki, H. (2024). The Current Status ofRegulation of Asian Small-Clawed Otters Aonyx cinereus Trade in Japan. IUCN Otter Spec.
Group Bull. 41 (1): 4 - 14
Keywords: CITES, conservation, exotic pets, law enforcement, Mustelidae, wildlife trade

INTRODUCTION
Illegal and/or unsustainable trade in wildlife is a threat to the survival of anincreasingly long list of species (Eaton et al., 2015; Marshall et al., 2020). Among these
are the 13 extant species of otters in the world, many of which are threatened due todemand for pelts, parts for use in traditional medicines, and as pets (Duplaix andSavage, 2018). Perhaps the most heavily traded otter species to supply demand for petsis the Asian Small-clawed Otter Aonyx cinereus (Gomez and Bouhuys, 2018). Foundthroughout much of East, South and Southeast Asia (Wright et al., 2021), the Asian
Small-clawed Otter is assessed as Vulnerable by the IUCN Red List of Threatened
Species and is reported to be threatened by habitat loss, loss of prey and increasing trade(Wright et al., 2021). This species is frequently found in international wildlife markets,on online trade platforms and displayed in animal cafes (Aadrean, 2013; Gomez et al.,2016; Gomez and Bouhuys, 2018; Kitade and Naruse, 2018; Siriwat and Nijman, 2018,
Sigaud et al., 2023). Its small size, active behaviour, and attractive appearance havemade it a favourite among exotic pet keepers, and by extension, among poachers andwildlife traffickers. Due to the imminent threat to its survival from illegal andunsustainable trade, the Asian Small-clawed Otter was listed in 2019 in Appendix I of
the Convention on International Trade in Endangered Species of Wild Fauna and Flora(CITES) which generally prohibits international trade, elevated from Appendix II.
Since then, there has been one import only for scientific purposes, and no seizure
records were reported in the CITES Trade Database (htpps://trade.cites.org) or-4-

IUCN Otter Spec. Group Bull. 41(1) 2024

TRAFFIC’s Wildlife Trade Information System (WiTIS) in Japan. The Asian Smallclawed Otter is protected as an "Internationally Rare Species of Wild Fauna and Flora"
under domestic law in Japan, and since the Appendix I listing, legislation regulating the
trading of Asian Small-clawed Otters has become rigid. However, Asian Small-clawed
Otters obtained prior to the regulation or animals bred in captivity using individuals
obtained prior to the regulation can still be traded for commercial purposes underindividual otter registration with the Ministry of the Environment. This study focuseson the current status of pet otters regulation in Japan following the elevation of thisspecies from Appendix II to Appendix I of CITES.
METHODS
To better understand the current status of otter trade in Japan, and the impact
listing the species in CITES Appendix I in 2019 has had, we have carried out thefollowing:
1. We analysed international trade data from the CITES Trade Database todetermine the past and recent role of Japan in the international trade in Asian
Small-clawed Otters.
2. We looked at trade levels prior to and after the up-listing of the species fromCITES Appendix II to Appendix I in 2019 to determine changes in trade levels.
3. We investigated the current levels of trade in Asian Small-clawed Otters forpets in Japan.
4. We looked for recent enforcement records relating to the illegal trade in thisspecies.
5. We looked into the current demand and use of Asian Small-clawed Otters inanimal cafes in Japan.
6. We explain the new legislation in Japan to regulate and control the trade in
Asian Small-clawed Otters to better understand the strengths and weaknesses ofthis legislation and the potential impacts it will have on the trade in this species.
7. Finally, we have made recommendations to further prevent the illegal trade in
Asian Small-clawed Otters in Japan.
RESULTS
Past Pet Otter Trade and Changes in CITES Regulations
International trade of live Asian Small-clawed Otters
International trade in the Asian Small-clawed Otter is not new. In the past, many
Asian Small-clawed Otters were exported from Thailand to the United States ofAmerica and the United Kingdom for pets before Thailand stopped the export in the
mid-1970s (Foster-Turley, 1992). Between 1977 and 2019, a total of 1160 live
individuals had been traded worldwide for all purposes as reported by importing
countries in the CITES Trade Database (Table 1). Of this total, 681 otters were tradedfor personal use and commercial trade (Purpose codes P and T, respectively) (Table 2).
During this period, Japan imported the largest number of live individuals (n = 354),
while the Netherlands exported the largest number of live individuals (n= 110).

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Table 1. Number of live Asian Small-clawed Otters traded for all purposes between 1977 and 2019 (byimport declaration numbers on CITES Trade Database)
Importing Countries
Japan
United States of America
China
Korea
Uzbekistan
Others
Total

No.
382
127
124
106
100
327
1160

Exporting Countries
Netherlands
Czech RepublicSingapore
Indonesia
Tanzania
Others
Total

No.
148
115
110
109
100
578
1160

Table 2. Number of traded live Asian Small-clawed Otters for personal and commercial purposes
between 1977 and 2019 (by import declaration numbers on CITES Trade Database; Purpose codes are P
and T)
Importing Countries
Japan
Uzbekistan
United States of America
Singapore
Korea
Others
Total

No.
354
100
98
45
24
60
681

Exporting Countries
Netherlands
Tanzania
Indonesia
Singapore
Czech Republic
Others
Total

No.
110
100
89
83
67
232
681

Import of Live Asian Small-clawed Otters to Japan
There were 382 live Asian Small-clawed Otters imported into Japan between
1986 and 2019 for all purposes, but since 2020, there has been one import only for
scientific purposes, and no illegal imports of this species were reported in Japan.
Imports increased in the latter half of the 1980s and again in the latter half of the 2010s(Figure 1). During the first peak in the latter half of the 1980s, most were imported forcommercial purposes. As it was not common to keep otters as pets in households at thattime, it is likely that demand came from zoos and aquariums that used the species in
exhibitions. Asian Small-clawed Otters began to be kept in zoos and aquariums in Japan
in 1970. Although a total of four individuals were exhibited in two zoos at first(Japanese Association of Zoos and Aquariums, 1970), the number of individuals in zoos
and aquariums increased to 22 by 1995, and there were 228 in total in 39 facilities in
2013. It has been suggested that this increase was due to the Asian Small-clawed Otters
being considered attractive as exhibition animals, that they were easy to obtain, andallegedly breed throughout the year with relatively large litter sizes (Wakiguchi, 2015).

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IUCN Otter Spec. Group Bull. 41(1) 2024

Figure 1. Changes in the number of otters imported by Japan from 1986 to 2019Illegal Trade of Live Asian Small-clawed Otters in Asia and JapanThe high demand and increasing profits to wildlife traders has led to an increasein illegal trade in this species. In Southeast Asia, 32 live Asian Small-clawed Otterswere seized between 2015 and 2017, with Thailand as the major hub of illegal trade(Gomez and Bouhuys, 2018). There was an increase in the trafficking of this species
into Japan with at least 10 cases of smuggling or attempted smuggling of 62 Asian
Small-clawed Otters into the country, largely from Indonesia and Thailand between
2000 to 2019 (Shepherd and Tansom, 2013; Kitade and Naruse, 2018). It is reasonable
to assume that these seizures represent a mere fraction of the actual number of Asian
Small-clawed Otters trafficked from a range of countries into Japan and, continued
seizures and arrests indicate profitable incentives for successfully smuggling otters into
Japan’s market (Kitade and Naruse, 2018).
Up-Listing to CITES Appendix I in 2019In 1977, the Asian Small-clawed Otter was listed in Appendix II of theConvention on CITES (UNEP-WCMC, 2022). However, the Parties decided to list the
Asian Small-clawed Otter in Appendix I in August 2019, as excessive trade due toescalating demand for pets would increase the risk of extinction of this endangered
species. As a result, international commercial transactions have been prohibited inprinciple since 26 November 2019.
Current Situation of Pet Otter Trade
International Trade of Live Asian Small-Clawed Otters
Since the Asian Small-clawed Otter was listed in CITES Appendix I,
international trade for commercial purposes of this species has been prohibited inprinciple, with possible exceptions for animals bred in captivity at facilities registeredwith CITES. Trade for scientific purposes is still allowed with permissions issued by
the government of both the exporting and importing countries. Based on the CITES
trade database between 2020 to 2021, one import for commercial purposes from the-7-

IUCN Otter Spec. Group Bull. 41(1) 2024

Czech Republic to South Korea was reported in 2021 (Table 3). However, as there areno breeding facilities in the world registered with CITES for this species, it is unclear
how this trade was conducted.
Table 3. Record of traded live Asian Small-clawed Otters for all purposes between 2020 and 2021 (byimport declaration numbers on CITES Trade Database; Purpose codes are all)
Year

Importer

2020
CH
2020
MA
2020
ZA
2021
JP
2021
KR
2021
KR
2021
NZ
2021
ZA
AU Australia
CH Switzerland
CZ Czechia
DK Denmark
FR France
HK Hong Kong (China)
JP Japan
KR Republic of Korea
MA Morocco
NZ New Zealand
SG Singapore
ZA South Africa

Exporter

Importer
Reported
Quantity

CZ
FR
SG
HK
CZ
DK
AU
SG

1
5
2

Exporter
Reported
Quantity
1

2
2

Purpose

Source

Z
B
B
S
T
Z
Z
B

C
F
C
F
C
C
C
C

B For breeding in captivity
C Bred in captivity (both parents captive bred)
F Born in captivity but not bred in captivity
S Scientific
T Commercial
Z Zoo or Aquarium

While the international trade of the species into Japan has declined since the
CITES Appendix I listing, there are still reports of illegal trade in some range states.
According to TRAFFIC’s WiTIS, there were a total of 16 seizures involving 54 live
Asian Small-clawed Otter reported from November 26th 2019 until December 31st 2021.
There were eight seizures with a total of 34 live Asian Small-clawed Otters in Vietnam,
and eight seizures with a total of 20 live Asian Small-clawed Otters in Thailand. In
most of the cases, advertisements of live otters for sale as pets were posted on social
media such as Facebook.
The Asian Small-clawed Otter is protected under domestic laws in all Southeast
Asian countries except Cambodia and Indonesia, with the latter regulating trade on
paper under a national quota system (Gomez and Bouhuys, 2018). However, as can beseen from these data, illegal trade persists in many countries despite national laws.
Law Enforcement and Market of Pet Otters in JapanDue to elevation of the Asian Small-clawed Otter from Appendix II to I of CITES,
the species has become subject to protection under domestic legislation in Japan, andregulations on management have changed significantly. Individual otter registration
with the Ministry of the Environment is now required for transaction or display for saleor distribution purposes.
However, the number of animal cafes exhibiting otters whose operation is legallyallowed in Japan has increased slightly since 2018. It can be seen from Google Trends
that general interest in otters in Japan remains at a high level, and the “demand” forkeeping otters as pets still exists. As it has been pointed out that Japanese social media-8-

IUCN Otter Spec. Group Bull. 41(1) 2024

posts calling for galagos to be pets are stimulating demand for pets globally (Svensson
et al., 2022), the pet demand of the Asian Small-clawed otters in Japan could indirectly
increase threats to the conservation of wild populations. In addition, there are concerns
about animal welfare because the act of “petting” can cause physical and mental stressto animals, and animals may be placed in environments different from their natural
habitats.
Legislation
Legal regulations regarding the Asian Small-clawed Otter in Japan wereintroduced through the Act on Conservation of Endangered Species of Wild Fauna andFlora 1992 (ACES) and the Act on Welfare and Management of Animals 1973, which
are the primary laws regarding domestic trade and keeping of animals.
1. Act on Conservation of Endangered Species of Wild Fauna and Flora (ACES)The ACES is a law enacted in 1992 to conserve species that are designated asnationally endangered species as well as internationally threatened species
listed in CITES Appendix I, or Conventions and Agreements for Protection ofMigratory Birds. Accordingly, the Asian Small-clawed Otter was designated asan Internationally Rare Species of Wild Fauna and Flora under ACES from
November 26th, 2019, onwards. In principle, the transaction referring totransfers (giving, selling, lending, receiving, buying, and borrowing) ofendangered species is prohibited. Display and advertising for the purpose of saleor distribution leading to a transaction are also subject to regulation. Therefore,
to transact, display or advertise for individuals that meet certain conditions suchas being obtained prior to the application of ACES regulations or animals bredin captivity using individuals obtained prior to ACES regulations, each Asian
Small-clawed Otter must be individually registered through the designatedinstitution by the Ministry of the Environment of Japan. Additionally, a
registration card showing the registration number, registration date, andexpiration date must be provided during the transaction or display andadvertising for sale or distribution.
2. Act on Welfare and Management of Animals
The Act on Welfare and Management of Animals was enacted in 1973 andstipulates standards for the care and management of animals to ensure theirhealth and safety and prevent animals from causing harm or inconvenience tohumans. This law is not related to CITES implementation, and therefore, theregulation of the Asian Small-clawed Otter under this law has not changed.
However, the Act on Welfare and Management of Animals stipulates various
regulations regarding businesses dealing with animals, and face-to-face
explanations and physical confirmation of animals are required for dealers whenselling mammals, birds, and reptiles to customers, restricting the online trade in
Asian Small-clawed Otters in Japan.
MarketOnce a species is listed in Appendix I of CITES, international trade is prohibitedin principle. In the case of the Asian Small-clawed Otter, no import record to Japan has
been confirmed since 2019. Many cases of sales of otters at exotic pet fairs or online
advertisements were observed in Japan before the change (Kitade and Naruse, 2018),-9-

IUCN Otter Spec. Group Bull. 41(1) 2024

but as of 2022, multiple dealers say on their websites that they have suspended theirsale of otters because it has become difficult to import otters.
However, there are still several shops or animal cafes selling or leasing otters bredin captivity with registration numbers. In 2020, the number of Asian Small-clawed
Otters registered by the Ministry of the Environment of Japan was 31, and as of July
2022, it was 95. Although it is thought that the quantity of otters on the pet market in
Japan has decreased significantly due to import restrictions, this indicates that there arestill some otters being traded within Japan.
Otter Cafes
From the latter half of the 2000s, the overall pet trade and posts on social media
platforms of the Asian Small-clawed Otters has increased, likely encouraged by the factthat this species was featured as a cute “pet” in local TV programmes in Japan (Kitade
and Naruse, 2018). Furthermore, in Japan, Asian Small-clawed Otters are not only kept
as household pets but are also in demand for display at animal cafes (Kitade and Naruse,
2018; McMillan, 2018), some known as otter cafes, indicating the popularity of theseanimals.
Otter cafes usually offer otters on display and petting opportunities, but somefacilities also legally breed and sell individuals by highlighting the “cuteness” of otters.
In addition to stimulating demand, there are also concerns about animal welfare andpublic health related to keeping animals at these cafes. In many facilities, otters areplaced in small spaces without swimming facilities and fed mainly cat food, which is
not considered to be a sufficient or nutritional diet according to a nutritional study ofthe species (Cabana et al., 2022). There have been reports of health problems in someotters kept at these cafes that are thought to be likely caused by a lack of proper careand the stress of constant interactions with customers (Okamoto et al., 2020).
Furthermore, eating and drinking by customers in direct contract with wild animals,
such as otters, likely increases the risk of zoonotic diseases (Sigaud et al., 2023).
We investigated the current situation of otter cafes, which are believed to have amajor impact on stimulating demand for otters as pets. As of July 2022, Asian Smallclawed Otters were exhibited at 12 otter cafes in seven cities, with the largest numberof four otter cafes in Tokyo (Figure 2). This data shows the number of otter cafes has
increased slightly compared to the number of ten facilities observed by TRAFFIC in2018 (Kitade and Naruse, 2018).

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IUCN Otter Spec. Group Bull. 41(1) 2024

Figure 2. Locations of otter cafes in Japan confirmed in July 2022.

Demand for Pet Otters
To understand the trends in the general public’s interest in otters in Japan, we
searched for the word "カワウソ" (meaning “otter” in Japanese) from July 1, 2010, toJuly 1, 2022, using Google Trends (Figure 3). The search frequency of this word
gradually increased from around 2013, peaked in August 2017, and was about half ofthe peak in November 2019 when the Asian Small-clawed Otter was listed in Appendix
I of CITES.
Since the search trends include searches for other purposes, it is impossible toknow the accurate demand for Asian Small-clawed Otters as pets. However, it isinferred that the general public in Japan still has a high interest in this species.

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IUCN Otter Spec. Group Bull. 41(1) 2024

Figure 3. Google Trends for the term “カワウソ” (meaning “otter” in Japanese) from July 1, 2010 toJuly 1, 2022. Google Trends shows the relative popularity of the search term by setting the highest point
to 100.

CONCLUSION
Since the inclusion of Asian Small-clawed Otters in Appendix I of CITES in
2019, the international trade volume of Asian Small-clawed Otters has decreased
markedly. However, in many parts of the Asian region, illegal domestic trade is still
conducted mainly on online platforms.
Japan, historically one of the major consuming countries for Asian Small-clawed
Otters as pets, has had no new reports of imports or smuggling since it was listed in
CITES Appendix I, according to CITES and WiTIS records. It became significantly
difficult for dealers to trade this species due to significant decline in import volumes
and tightening regulations under Japanese domestic law, and the number ofadvertisements of otters for sale seems to have decreased.
Individuals imported before the tightening of regulations and their offspring canstill be traded if they are registered with the government. Some dealers sell captivebred individuals, so a certain amount of pet use is expected to continue in the future.
This should be closely monitored to prevent unscrupulous trade to other countries withdemand for this species.
Social media and animal cafe exhibits are the main drivers creating demand forpet otters and other exotic pets. In particular, there are many concerns about animal
cafes, which display wild animals such as otters, not only from the perspective of
stimulating demand but also from the perspective of animal welfare and public health.
Efforts should be made to continue to reduce demand for Asian Small-clawed
Otters in Japan and in all countries where this threatened species is traded. Specifically,
it would be effective for the private sector to eliminate displays of this species at animal
cafes, which may stimulate demand for pets. Demand is also expected to be reduced if- 12 -

IUCN Otter Spec. Group Bull. 41(1) 2024

appropriate information, including the threatened situation of Asian Small-clawed
Otters and the impact of trade, is conveyed to consumers on social media or the mass
media, eliminating messages that encourage them to keep this species as pets. In
addition, researchers around the world will help foster social momentum to reducedemand for Asian Small-clawed Otters as pets by clarifying pet use and its adverse
effects on this species.
Listing the Asian Small-Clawed Otter in Appendix I of CITES has led to a rapid
reduction in legal international trade and seizure records. However, as illegal trade isstill being reported in the country of origin, crackdowns should be strengthened byfurther clarifying and publicizing cases of illegal trade, seizures, and resulting
prosecutions by the authorities of each country. Furthermore, care should be taken not
to shift demand and trade of this species from countries with tighter regulations tocountries with looser regulations and enforcement.
Acknowledgements - We thank Loretta Shepherd, Melissa Savage and Lalita Gomez for very helpfulcomments and edits on a previous draft. We also thank Naoya Ohashi for his help in finding references.

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RESUMEÉTAT ACTUEL DE LA RÉGLEMENTATION DU COMMERCE DESLOUTRES CENDRÉES Aonyx cinereus AU JAPON
La loutre cendrée, Aonyx cinereus, est l’objet d’un commerce international en vue derépondre à la demande d’animaux de compagnie, à la fois légalement et illégalement.
En 2019, l'espèce est passée de l’Annexe II de la Convention sur le commerce
international des espèces de faune et de flore sauvages menacées d’extinction (CITES)à l’Annexe I, qui interdit généralement le commerce international, car son commerce
est considéré comme une menace pour la conservation de l’espèce. Bien que lalégislation nationale japonaise protège strictement les espèces inscrites à l’Annexe I dela CITES, il est toujours possible de commercialiser la loutre cendrée au niveau
national, sous réserve de procédures d’enregistrement nécessaires. Nous examinons ici
les niveaux actuels du commerce des loutres cendrées au Japon et l’impact de leurinscription aux annexes de la CITES.
RESUMENEL ESTADO ACTUAL DE LA REGULACIÓN DEL COMERCIO DE
NUTRIAS DE UÑAS PEQUEÑAS ASIÁTICAS Aonyx cinereus EN JAPÓN
La Nutria de Uñas Pequeñas Asiática Aonyx cinereus es comerciada
internacionalmente para proveer a la demanda de mascotas, tanto legal como
ilegalmente. En 2019, la especie fue elevada de estar listada en el Apéndice II de laConvención sobre el Comercio Internacional de Especies Amenazadas de Fauna y
Flora Silvestres (CITES), al Apéndice I, que en general prohíbe el comerciointernacional, ya que se estimó que el comercio es una amenaza a la conservación deésta especie. Aunque la legislación nacional Japonesa protege estrictamente a las
especies del Apéndice I de CITES, es aún posible comerciar internamente Nutrias deUñas Pequeñas Asiáticas, sujeto a los necesarios procedimientos de registro. Aquíanalizamos los niveles actuales de comercio de Nutrias de Uñas Pequeñas Asiáticas en
Japón, y el impacto del cambio en el listado de CITES.

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